The defendant is charged [in count __]
with forgery in the first degree. The statute defining this offense reads in
pertinent part as follows:

a person is guilty of forgery in
the first degree when, with intent to (defraud / deceive / injure) another,
(he/she) <insert as appropriate:>

falsely (makes /
completes / alters) a written instrument,

(issues /
possesses) any written instrument that (he/she) knows to be forged,

which is or purports to be, or
which is calculated to become or represent if completed, <insert as
appropriate:>

part of an issue of
money, stamps, securities or other valuable instruments issued by a government
or governmental instrumentality.

part of an issue of
stock, bonds or other instruments representing interests in or claims against a
corporate or other organization or its property.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Made, issued,
falsified or possessed a written instrumentThe first element is that the
defendant <insert as appropriate:>

falsely (made /
completed / altered) a written instrument.

(issued /
possessed) any written instrument that (he/she) knew to be forged.

A "written
instrument" is any instrument or article containing written or printed
matter or the equivalent thereof, used for the purpose of reciting, embodying,
conveying, or recording information or constituting a symbol or evidence of
value, right, privilege or identification, which is capable of being used to the
advantage or disadvantage of some person. A "forged
instrument" means a written instrument which has been falsely made,
completed or altered.

For first degree forgery, the written
instrument must be <insert as appropriate:>

part of an issue of
money, stamps, securities or other valuable instruments issued by a government
or governmental instrumentality.

part of an issue of
stock, bonds or other instruments representing interests in or claims against a
corporate or other organization or its property.

A written
instrument may be complete or incomplete. A "complete
written instrument" is a written instrument that is fully drawn with respect to every
essential feature thereof, whereas an "incomplete
written instrument" is one that contains some matter by way of content or authentication
but requires additional matter in order to render it a complete written
instrument.

(he/she) makes or draws a complete written
instrument in its entirety, or an incomplete written instrument, which purports
to be an authentic creation of its ostensible maker or drawer, but which is not
such either because the ostensible maker or drawer is fictitious or because, if
real, (he/she) did not authorize the making or drawing thereof.

(he/she) signs (his/her) own name to a written instrument, thereby falsely and fraudulently representing that (he/she) has authority to sign in such capacity.

(he/she), by adding, inserting or changing
matter, transforms an incomplete written instrument into a complete
one, without the authority of anyone entitled to grant it, so that such complete
instrument appears or purports to be in all respects an authentic creation of or
fully authorized by its ostensible maker or drawer.

(he/she) signs (his/her) own name to a written instrument, thereby falsely and fraudulently representing that (he/she) has authority to sign in such capacity

(he/she), without the authority of anyone entitled
to grant it, changes a written instrument, whether it be in complete or
incomplete form, by means of erasure, obliteration, deletion, insertion of new
matter, transposition of matter, or in any other manner, so that such instrument
in its thus altered form appears or purports to be in all respects an authentic
creation of or fully authorized by its ostensible maker or drawer.

(he/she) signs (his/her) own name to a written instrument, thereby falsely and fraudulently representing that (he/she) has authority to sign in such capacity.

The term "falsely" does not refer to
the content or tone of the writing, or to the fact stated in the writing, but
implies that the paper is false, not genuine, fictitious, not a true writing,
without regard to the truth or falsehood of the statement it contains.]

"Issuing" means
signing, endorsing, circulating, distributing, publishing or the like. The
state must prove that the defendant knew that the <insert type of written
instrument> was forged. A person acts "knowingly"
with respect to conduct or circumstances when (he/she) is aware that (his/her)
conduct is of such nature or that such circumstances exist. <See
Knowledge, Instruction 2.3-3.>]

"Possession" means
either actual possession or constructive possession. Actual possession means
actual physical possession, such as having the object on one's person.
Constructive possession means having the object in a place under one's dominion
and control. The state must prove that the defendant knew that the <insert
type of written instrument> was forged. <See
Possession, Instruction 2.11-1.>]

Element 2 - IntentThe second element is that the
defendant had the specific intent to (deceive / defraud / injure) another
person. A person acts "intentionally"
with respect to a result when (his/her) conscious objective is to cause such
result. <See
Intent: Specific, Instruction 2.3-1.>

Conclusion

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant (falsely made / falsely
completed / falsely altered / issued / possessed) a <insert type of written
instrument> [<insert only if the allegation is issuing or possessing>
that (he/she) knew to have been forged], and 2) (he/she) intended to (deceive /
defraud / injure) another person.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
forgery in the first degree, then you shall find the defendant guilty. On the
other hand, if you unanimously find that the state has failed to prove beyond a
reasonable doubt any of the elements, you shall then find the defendant not
guilty.